Exhibit 33.2



ASSESSMENT OF COMPLIANCE
WITH THE APPLICABLE SERVICING CRITERIA



Corporate Trust Services
division of Wells Fargo Bank, National Association (the “Company”) is responsible for assessing compliance with the
applicable servicing criteria set forth in Item 1122(d) of Regulation AB of the Securities and Exchange Commission. The Company
has determined that the servicing criteria are applicable in regards to the servicing platform for the period as follows:



Platform: Publicly-issued
(i.e., transaction-level reporting initially required under the Securities Exchange Act of 1934, as amended) and certain privately-issued
(i.e., for which transaction-level reporting is required pursuant to contractual obligation) residential mortgage-backed securities,
commercial mortgage-backed securities and other asset-backed securities, for which the Company provides master servicing, trustee,
securities administration or paying agent services, excluding any such securities issued by any agency or instrumentality of the
U.S. government (other than the Federal Deposit Insurance Company) or any government sponsored entity, and further excluding the
transactions issued prior to 2006 for which Wells Fargo outsources all material servicing activities (as defined by Regulation
AB) (the “Platform”).



Applicable Servicing
Criteria: All servicing criteria set forth in Item 1122(d), to the extent required in the related transaction agreements, or
required by the Item 1122(d) servicing criteria in regards to the activities performed by the Company, except for the following
criteria: 1122(d)(4)(ii), 1122(d)(4)(iv), 1122(d)(4)(v), 1122(d)(4)(viii), 1122(d)(4)(ix), 1122(d)(4)(x), 1122(d)(4)(xi), 1122(d)(4)(xii)
and 1122(d)(4)(xiii), which Management has determined are not applicable to the activities the Company performs with respect to
the Platform (“the Applicable Servicing Criteria”).



Period: As of
and for the twelve months ended December 31, 2012 (the “Period”).



Third parties classified as vendors:
With respect to servicing criterion 1122(d)(4)(i), the Company has engaged a vendor to handle certain Uniform Commercial Code filing
functions required by the servicing criterion. The Company has determined that this vendor is not considered a “servicer”
as defined in Item 1101(j) of Regulation AB, and the Company elects to take responsibility for assessing compliance with the portion
of the servicing criterion applicable to this vendor as permitted by Interpretation 17.06 of the SEC Division of Corporation Finance
Manual of Publicly Available Telephone Interpretations (“Interpretation 17.06”). The Company has policies and procedures
in place to provide reasonable assurance that the vendor’s activities comply in all material respects with the servicing
criterion applicable to the vendor. The Company is solely responsible for determining that it meets the SEC requirements to apply
Interpretation 17.06 for the vendor and related criterion.



With respect to the
Platform and the Period, the Company provides the following assessment of compliance with respect to the Applicable Servicing Criteria:



1. The Company is responsible
for assessing its compliance with the Applicable Servicing Criteria.



2. The Company has assessed compliance with
the Applicable Servicing Criteria, including the servicing criterion for which compliance is determined based on Interpretation
17.06 as described above. In performing this assessment, management used the criteria set forth by the Securities and Exchange
Commission in paragraph (d) of Item 1122 of Regulation AB.



3. Based on such assessment,
the Company has complied, in all material respects with the Applicable Servicing Criteria, except as described in Schedule A hereto.















4. Schedule B hereto
includes Management's discussion of the exceptions noted in Schedule A, including remediation efforts taken by the Company.



KPMG LLP, an independent
registered public accounting firm, has issued an attestation report on the Company’s compliance with the Applicable Servicing
Criteria for the Period.



| | WELLS FARGO BANK, National Association
| | --------------------------------------
| |                                       
| | By:                                   
| |                                       
| | Title:                                
| | Dated:                                















Schedule A



Material Instances of Noncompliance by
the Company



Management’s assessment of compliance
with the Applicable Servicing Criteria set forth by the Securities and Exchange Commission in paragraph (d) of Item 1122 of Regulation
AB as of December 31, 2012 and for the Period, disclosed that material instances of noncompliance occurred with respect to the
servicing criteria set forth in both of Items 1122(d)(3)(i)(B) and 1122(d)(3)(ii), as follows:



| | · | With respect to servicing criterion 1122(d)(3)(i)(B), certain reports to investors did not provide
information calculated in accordance with the terms specified in the transaction agreements.
| | - | -----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



| | · | With respect to servicing criterion 1122(d)(3)(ii), certain amounts due to investors were not allocated
and remitted in accordance with timeframes, distribution priority and other terms set forth in the transaction agreements.
| | - | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------



Schedule B



Management’s Discussion on Material
Instances of Noncompliance by the Company



Disclosure: During the Period, Wells
Fargo identified Payment Errors (as defined below) and Reporting Errors (as defined below) on certain residential mortgage-backed
securities (“RMBS”) transactions in the Platform. Although no individually identified error, in and of itself,
was found to be material to the Platform, when the errors were considered in the aggregate, Management determined that, for Platform
purposes, there were material instances of noncompliance with respect to both Items 1122(d)(3)(i)(B) and 1122(d)(3)(ii) of Regulation
AB.



For purposes of this
Schedule B, the term “Payment Errors” means the identified payment errors that occurred during the Period
and that, when considered in the aggregate, led to Management’s determination that there was a material instance of noncompliance
for the Platform with respect to Item 1122(d)(3)(i)(B) of Regulation AB. For purposes of this Schedule B, the term “Reporting
Errors” means the identified reporting errors that occurred during the Period and that, when considered in the aggregate,
led to Management’s determination that there was a material instance of noncompliance for the Platform with respect to Item
1122(d)(3)(ii) of Regulation AB.



The identified Payment
Errors and Reporting Errors on such RMBS transactions were attributable to certain failures in processes relating to waterfall
calculations and reporting that, although adapted over time, still insufficiently addressed the impact of the unprecedented levels
of collateral degradation in RMBS transactions on the calculation of principal and interest payments and losses and associated
investor reporting.



Scope of the Material Instances of Noncompliance:
The identified Payment Errors and Reporting Errors that led to Management’s determination that material instances of noncompliance
with respect to the Platform had occurred were limited to certain RMBS transactions in the Platform. There were no identified Payment
Errors or Reporting Errors for non-RMBS transactions in the Platform which contributed to Management’s determination that
there were material instances of noncompliance for the Platform. In some instances, the identified Payment Errors which contributed
to Management’s determination that there were material instances of noncompliance for the Platform were also considered material
to the transactions on which they occurred. None of the identified Reporting Errors which contributed to Management’s determination
that there were material instances of noncompliance for the Platform were considered material for a particular transaction. For
all transactions in the Platform (including RMBS transactions with identified Payment Errors and Reporting Errors), Management
delivered an Item 1123 certification to the extent it was required to do so pursuant to the requirements of the applicable transaction
documents and Regulation AB. Where there was an identified Payment Error that was considered material for an individual transaction,
the Item 1123 certification included a description of the nature and scope of such error.















Remediation: Appropriate actions
have been taken or are in the process of being taken to remediate the identified Payment Errors and Reporting Errors that led to
Management’s determination that material instances of noncompliance with respect to the Platform had occurred. Further, adjustments
have been or will be made to the waterfall calculations and other operational processes and quality control measures applied to
the RMBS transactions in the Platform to minimize the risk of future payment and reporting errors.



Material Instance of Noncompliance
by any Vendor



NONE



Material Deficiencies in Company’s
Policies and Procedures to Monitor Vendor’s Compliance



NONE